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PRIVACY POLICY



Contents

 * Introduction
 * Our contact details
 * Data Controllers
 * Data Protection Officer
 * The personal data we process
 * How we store your personal information
 * Our third parties
 * International transfers
 * How You Can Set Your Data & Privacy Preferences
 * For Individuals Who Are in The UK and European Economic Area: Your Rights
 * How to Exercise Your Rights
 * Additional Disclosures for California Residents
 * Additional Disclosures for Individuals in the People’s Republic of China


INTRODUCTION

Delinian is a global information business providing essential B2B information to
global and specialist markets.Delinian and its group companies are committed to
respecting the privacy of every person who visits, registers with or subscribes
to our websites, publications, events and other products or services, or about
whom we otherwise collect personal data.

 


OUR CONTACT DETAILS

Name: Delinian, a business registered in England and Wales with registration
number 00954730.
Address: 4 Bouverie Street, London, EC4Y 8AX
E-mail: dataprotectionofficer@delinian.com

This privacy notice describes how we use your personal data. Please read it
carefully along with our Cookies Notices. We may make changes to this notice
from time to time, so please check it regularly. We will make you aware when it
has been updated. 


DELINIAN DATA CONTROLLERS

This privacy notice explains how the members of the Delinian Group collect, use
and protect personal information across our brands. References to “we”, “us” or
“our” are to the relevant Delinian Controller processing your personal
information.

Delinian is a global information business providing actionable data, analysis,
intelligence and access through a range of brands in markets where information
and convening participants is valued.

Usually when we interact with you it will be through one of our brands. The
Delinian legal entity that is responsible for personal data (referred to as the
data controller in the EU/UK and referred to as the Delinian Controller in this
privacy notice) will be the entity shown on booking, web and contract forms or
invoices if the legal entity is a UK entity, and Delinian Limited if the legal
entity is a US or Canadian entity. Different Delinian legal entities are
responsible for different events and products. For example, Delinian (IJ Global)
Limited operates the IJ Global and Power Finance & Risk brand and Ned Davis
Research Inc operates the NDR brand.

This Privacy Notice applies to all Delinian businesses. Some of our businesses
may also have their own policies, which will be relevant to you when you are
using those sites and services. To complement our global approach to privacy
protection, this policy also incorporates specific information privacy rights
granted to individuals under California and Chinese privacy laws. This reflects
our relationship with our customers in these locations.


DATA PROTECTION OFFICER

If you wish to exercise your rights under data protection law, you can do so by
contacting us at the details under the heading How to exercise your rights.


THE PERSONAL DATA WE PROCESS

Delinian Controllers collect your personal data when you visit our sites and
apps, subscribe for products or services, register for,
and attend our events, contribute to our businesses or when you otherwise
interact with us. We have described below
the personal data that we process, what we use it for and where we get it from
(which, in each case, may vary
depending on the way in which you engage with us).

Personal data that you provide to us when you register with one of our websites
and/or sign
up for a free trial of our products or services. This includes your name,
address, email address and
telephone number and details relevant to your occupation and employer. It will
also include payment
details. To provide you with the product and/or service that you have requested.
Our lawful basis is that it is
necessary to process this information to fulfil the contract we are about to
enter into or have entered
into with you. You Personal data that you provide when you register for one of
our events. This includes your
name, address, email address and telephone number and details relevant to your
occupation and employer. It
will also include payment details. To complete your registration for an event
and to allow you to participate in the event. Our lawful
basis is that it is necessary to process this information to fulfil the contract
we are about to enter
into or have entered into with you. You Personal data that you provide to us
when you engage with us that relates to your health. So that we are able to make
reasonable adjustments due a personal condition that you may share with us. You
Personal data that you provide to us when you engage with us. To send marketing
to you. We rely on our legitimate interest to contact you in relation to
products
and/or services that may be of interest to you.We provide you with the
opportunity to object to receipt of marketing at the time we collect your
information, and you can change your preferences at any time. You Personal data
that you provide to us when you engage with us. To share with sponsors of our
events, or other business partners, so that they can contact you in relation to
products and/or
services that may be of interest to you.We rely on our legitimate interest to
share this information with our sponsors and other business partners for this
purpose. We
provide you with the opportunity to object to this information being shared. You
Information from apps, through your browser or device and your IP address
(“Transaction
Data”)This is statistical data and does not identify your individual device.
This might be your computer type,
screen resolution, operating system name and version, device manufacturer and
model, language and Internet
browser type and version for example.
 * To monitor usage and performance of our products, services, processes and
   platforms, perform
   analysis (e.g. statistical, market, product analysis), reporting and
   forecasting;
 * To understand how you interact with our products, services and platforms;
 * To perform checks and prevent, detect, investigate and report usage contrary
   to our terms and
   conditions.

We are relying on our legitimate interest to help us understand, develop,
improve our products and
services and our legitimate interest to manage risk and security.

 

Your device Personal data which relates to you and your employment – such as
email address, phone
number, job title, address, purchase history and account information To create
“segments” of particular audiences so that we can improve the quality and
relevance of our
sales and marketing activities and provide offers that are relevant to you and
your profile.We rely on our legitimate interest to market our products and
services. You Your personal data to create a “segment” of particular types of
audiences so that we can
show you advertisements which may be more relevant to you and the “segments” you
may be in.We use third parties to deliver cookies that collect technical
information, including how you interact
with our site (e.g. browsing information, which articles you have read etc) To
deliver advertisements to you which may be of interest to you.



We rely on our legitimate interest to market our products and services.

Where we use cookies or other tracking technology, please see our cookie notice
for more information and
detail on how to manage your cookie choices through your privacy settings.

Your device Some of your personal data together with Technical Data on your
device To share with third parties to deliver targeted advertising to you on
other websites (e.g Facebook
Customer Audiences). This could include your email address and cookies, web
beacons or other tracking
technology to monitor your online behaviour and identify website usage, helping
advertisers show you
advertising and content that is more relevant to you. This is also known as
behavioural advertising.Third parties, such as Facebook and Google, will have
their own privacy policies which you can find below:



 

Google

You can find more information about how Google uses data that it receives
here: https://policies.google.com/technologies/partner-sites

 

Facebook Custom Audience

For further details in relation to Facebook Custom Audience, please
visit https://www.facebook.com/legal/terms/customaudience.

Where we send data to Facebook, we are a Joint Controller with Facebook. This
Joint Controller
relationship is subject to Facebook’s Controller Addendum.

Facebook is the independent Data Controller once it is in receipt of that data.
You can find more
information about Facebook’s processing at https://www.facebook.com/policy.php

When processing your information for these purposes, we are relying on our
legitimate interest to help us
market our products and services.

You

Personal data which may allow us to contact you To share with trusted third
parties to verify the information that we hold and ensure that it remains
accurate.



We rely on our legitimate interest to provide you with our products and
services.

You and trusted third parties Personal data that allows us to contact you To
request your feedback and/or ask you to participate in customer and/or market
research.



We rely on our legitimate interest to understand, develop and improve our
products and services.

You Personal data that you submit on message boards, blogs or other services for
generating
content from users. So that you can contribute to online conversations and
communities available on our services.



Please be careful when deciding to post any personal data for this purpose. User
generated content is also
subject to our site Terms and Conditions.

We rely on our legitimate interest to provide information, opinions or ideas to
the public.

You Personal data that you have provided to us If we sell a business or assets,
we may need to disclose your personal data to the prospective buyer of
such business or assets. If Delinian, or any of our group companies, is sold or
sells our assets or is
acquired by a third party, then personal data about our customers will be
acquired by that third party. A
transfer of your personal data in these circumstances would be necessary so that
the services you have
contracted for can still be delivered, or so that you can continue to enjoy the
benefits of our products
and services. You will receive notice if a new controller assumes responsibility
for your personal data.



We rely on our legitimate interest to sell businesses for operational or
strategic purposes.

You Transaction Data We may include small pixel tags (small image files) within
the emails we send you in order to determine
whether our emails are opened and/or whether the hyperlinks inside our emails
are clicked through. We may
also collect browser, location and the device used to engage with our email
communications. This
information allows us to better understand whether we are meeting our users’
needs and how we can improve
our communications. No other information is collected.



We rely on our legitimate interest to understand, develop and improve our
products and services.

Your device Publicly available data To carry out sanctions screening to prevent
transactions with persons prohibited from certain
transactions and/or activities.



We rely on our legal obligation to carry out sanctions screening and our
legitimate interest to manage
risk, security and prevent crime and data that you provide to us.

Independently audited third parties. Publicly available data To send marketing
to you. We obtain such information from trusted sources.



We rely on our legitimate interest to contact corporate subscribers in relation
to products and/or
services that may be of interest.

We always provide the opportunity to object to receipt of future marketing at
the time we send materials
and provide the ability to change preferences at any time. We will not send
materials to persons who have
previously told us they do not want to receive marketing.

Trusted databases Publicly available data To provide information, opinions or
ideas to the public (journalism)



We rely on our legitimate interest in providing information, opinions or ideas
to the public, upholding
standards of integrity, promoting transparency and accountability, encouraging
public understanding and
securing the best use of public resources.

Through investigation Personal data that you have provided to us To protect the
security and resilience of our networks/applications and respond to technical
and
security incidents.



We rely on our legitimate interest to manage risk, security and crime
prevention.

You Personal data that you have provided to us To enable us to provide legal
and/or regulatory advice in line with our business activities.



We rely on our legitimate interest to satisfy our industry, regulatory and legal
requirements and exercise
our rights.

You


HOW WE STORE YOUR PERSONAL INFORMATION


DATA SECURITY

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and the relevant data protection regulator of a breach where
we are legally required to do so.


DATA RETENTION

We have a data retention policy that ensures we don’t use or store your personal
data for longer than necessary. We consider the following to determine retention
periods:

 * Guidance from the UK Information Commissioner and other regulatory agencies,
   as well as industry best practice recommendations;
 * The use(s) of the personal data;
 * The business rationale for collection and expiry of the purpose for which
   personal data was collected;
 * Our ongoing ability to ensure the accuracy of the data; and
 * Legal and regulatory requirements.

We may occasionally need to keep personal data for either shorter or longer
periods than specified in our retention policy. In such circumstances,
application of the retention period to the data will be temporarily suspended.
The suspension of any retention period will be carried out in a manner that
respects the rights and interests of all persons concerned.


OUR THIRD PARTIES

We use third parties to enable, perform or improve a range of our business
processes. These may require us to share your data with third parties and/or
they may share your data with us. These third parties may include (but are not
limited to):

 1. Third parties that enable us to understand, develop, improve and market our
    products and services;
 2. Third parties that enable us to carry our regulatory checks – for example
    sanctions screening;
 3. Third parties that work with us to help us fulfil on and service your
    products and services;
 4. Third parties that support the running of our business processes;
 5. Third parties that provide reporting, banking or tax management services and
    enable us to manage our business financials and performance;
 6. Other third parties, bodies or institutions where we are required by
    regulation, law, industry practices or to detect/prevent fraud, crime,
    terrorist activity or business risks eg regulators, law enforcement bodies
    and crime prevention bodies.

Some of our third parties may be international. See ‘International transfers’ to
understand how we manage our data internationally.


INTERNATIONAL TRANSFERS

The Delinian Group has over 30 offices around the world. Your data may be
transferred to or accessed globally.

As well as other Delinian  operations, the service providers we share your data
with may have operations in the UK, the EEA and elsewhere in the world.

While some countries – for example those in the European Economic Area (“EEA”),
the Isle of Man, Andorra, Argentina, Guernsey, Israel, Jersey, New Zealand,
Switzerland and Uruguay are recognised as having must have the same high
standard of data protection as offered in the UK, other parts of the world may
not guarantee that same level of protection. When we share your data with anyone
outside of the UK and the EEA, where necessary, we always put in place the
safeguards required by law to ensure that a consistent high level of protection
travels with your data.

If you would like more specific details about the safeguards in place when
transferring your data, please email dataprotectionofficer@delinian.com.


HOW YOU CAN SET YOUR DATA & PRIVACY PREFERENCES

You can use our Preference Centre to select the topics that are of interest to
you so that we can send you publications and information about our products and
services that are especially relevant to you. You can also choose the channels
we use to contact you (email, phone, post, etc.) and can also opt-out of
receiving communications.


FOR INDIVIDUALS WHO ARE IN THE UK AND EUROPEAN ECONOMIC AREA: YOUR RIGHTS

You have certain rights in relation to your personal data which include the
following:




YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

 * YOUR RIGHT OF ACCESS
   
   You have the right to ask us for copies of your personal information.

 * YOUR RIGHT TO RECTIFICATION
   
   You have the right to ask us to rectify personal information you think is
   inaccurate. You also have the right to ask us to complete information you
   think is incomplete.

 * YOUR RIGHT TO ERASURE
   
   You have the right to ask us to erase your personal information in certain
   circumstances.

 * YOUR RIGHT TO RESTRICTION OF PROCESSING
   
   You have the right to ask us to restrict the processing of your personal
   information in certain circumstances.

 * YOUR RIGHT TO OBJECT TO PROCESSING
   
   You have the right to object to the processing of your personal information
   in certain circumstances.

 * YOUR RIGHT TO DATA PORTABILITY
   
   You have the right to ask that we transfer the personal information you gave
   us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a
request, we have one month to respond to you.


HOW TO EXERCISE YOUR RIGHTS

To exercise any of these rights, please contact us by post or email at the
following addresses:

Data Protection Officer
Delinian Limited
4 Bouverie Street
London,
EC4Y 8AX
United Kingdom
Email: dataprotectionofficer@Delinian.com
Web form: Please click here
We may need to check your identity prior to processing a request. We will do our
best to respond to any questions and address any of your concerns.

You also have the right to complain directly to the Regulator regarding the
processing of your personal data – the Information Commissioner in the UK or the
regulatory body of the country where you live. You can contact the UK
Information Commissioner at the link provided or in writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

For other regulatory bodies, this information is readily available. But, you can
contact us at dataprotectionofficer@Delinian.com should you require assistance.


ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

We have explained our privacy practices in full in the other sections of this
Privacy Notice. In this section, we provide a list of the categories of personal
information set out in the California Consumer Privacy Act (“CCPA”) that have
been collected, the purposes for which those categories of information are
collected or used, and the business purposes (as defined in the CCPA) for which
those categories are disclosed. In the twelve months preceding the date this
Privacy Notice took effect, we have not sold personal information although we do
use standard Internet advertising and analytics tools provided by third parties
that rely on cookies and other tracking technologies (see our Cookie Settings
for more information), and we may disclose your information with your consent
and for the business purposes described below.

Categories of Personal Information Collected
 * Internet or other electronic network activity information, e.g., browsing
   history; search history; online interests, such as information about
   categories of consumer interests derived from online usage; and information
   on a consumer’s interaction with a website, application, or advertisement.
 * Demographic and statistical information, including information regarding
   personal characteristics of protected classifications under California law
   like race and gender
 * Device information and other personal identifiers, e.g., name; alias; postal
   address; online identifiers; IP address; email address; account name.
 * Professional, education, or employment-related information, e.g., business
   name or job title.
 * Geolocation information
 * Commercial or transactions information, e.g., records of personal property,
   products or services purchased, obtained, or considered, or other purchasing
   or consuming histories or tendencies.
 * Inferences, e.g., inferences drawn from the information identified in this
   Privacy Notice to create a profile about a consumer reflecting the consumer’s
   preferences, predispositions, behavior, etc.

Purposes for Which the Categories of Personal Information Are Collected or Used
 * To provide online platforms.
 * To communicate with you.
 * To improve and develop online platforms.

Purposes for Which the Categories of Personal Information are Disclosed for
Business Purposes or Sold We disclose these categories of personal information
for business purposes. For example, we share this information:



 * To our service providers.
 * To protect our lawful interests.

Subject to certain limitations, you have the right to: request to know more
about the categories and specific pieces of personal information we collect,
use, and disclose; request deletion of your personal information; opt out of any
“sales” of your personal information that may be occurring; and not to be
discriminated against for exercising these rights.

To access any of your rights described in this section (for customers who are
California Residents), please submit your request by submitting the CCPA Data
Request form. When you exercise your rights, we may seek to verify your
identity, for example by verifying purchases you have made with us. If we
receive your request from an authorised agent, we may ask for evidence that you
have provided such agent with power of attorney or that the agent otherwise has
valid written authority to submit requests to exercise rights on your behalf. If
you are an authorised agent seeking to make a request, please contact us. We
will not discriminate against you for exercising your rights.


ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE PEOPLE’S REPUBLIC OF CHINA


中华人民共和国境内个人额外披露事项

我们处理个人信息的法律依据

我们将依照合法、正当、必要、善意的原则处理您的个人信息。如有需要，我们将在处理您的个人信息之前取得您的同意。特别是，当我们处理您的敏感个人信息时，我们将按照法律、行政法规的规定，取得您的单独同意或书面同意。

如果我们对您的个人信息的处理超出本隐私声明的内容，我们将通过页面提示、互动流程、网站公告等方式向您单独说明处理的目的、方式和范围，并再次取得您的同意。

如果涉及直效营销，我们将征求您的同意。您始终有不作回应的自由，并可随时轻松撤回同意。

您完全知悉，在以下任一情形中，我们可以无需取得您的授权和同意而处理您的个人信息：

 * 为订立、履行您作为一方当事人的合同所必需，或者按照依法制定的劳动规章制度和依法签订的集体合同实施人力资源管理所必需；
 * 为履行法定职责或者法定义务所必需；
 * 为应对突发公共卫生事件，或者为保护自然人的生命健康和财产安全所必需；
 * 为公共利益实施新闻报道、舆论监督等行为，在合理的范围内处理个人信息；
 * 依照法律、行政法规的规定在合理的范围内处理您自行公开或者其他已经合法公开的个人信息；
 * 法律、行政法规规定的其他情形。

我们如何分享您的信息

我们不会与第三方分享您的个人信息，除非我们取得您的单独同意，或者按照法律法规的规定无需取得您的同意。

我们可能会与活动赞助商分享您的姓名、职务、公司、地址、电话号码和电子邮箱地址。由于活动赞助商不时变换，我们将在分享您的个人信息之前告知您赞助商的名称和联系方式以及处理的目的和方式，并取得您的单独同意。

如果我们因合并、分立、解散、被宣告破产等原因需要转移您的个人信息，我们将通知您接收方的名称或者姓名和联系方式，并敦促接收方继续根据本隐私声明处理您的个人信息。否则，我们将要求接收方在处理之前再次取得您的同意。

存储地点和国际转移

您的个人信息将被存储在中华人民共和国境外。Delinian
 Limited（https://www.Delinian.com）是一个全球性组织，其将接收您的个人信息（姓名、职务、公司、地址、电话号码和电子邮箱地址）。

我们还可能与公司的关联方分享您的个人信息，以便其向您发送营销材料。

我们将采取法律规定的必要措施，包括取得您的单独同意，与境外接收方签订标准合同条款以约定双方之间的权利和义务，确保外国接收方按照适用法律的规定对您的个人信息提供充分保护。

您可以通过本隐私声明中所列的联系方式与我们或海外接收方联系，以行使个人信息方面的权利。

您享有的额外隐私权利

根据《个人信息保护法》的规定，您享有以下权利：

 * 知情权：您有权知悉您的个人信息的处理情况。此外，您还有权要求我们解释本隐私声明以及我们处理个人信息的规则。
 * 查阅权和复制权：您可以要求查阅您的个人信息或者取得您的个人信息的副本。
 * 更正权和补充权：如果您发现您的个人信息不准确或不完整，可以要求我们予以更正或补充。
 * 删除权：在某些情形下（例如：您撤回了同意，或者处理个人信息的目的已经实现、无法实现或者为实现处理目的不再必要），您可以要求删除您的个人信息。
 * 转移权：当符合有关部门规定的条件时，您可以将您的个人信息转移至您指定的个人信息处理者。
 * 作出决定、限制和拒绝的权利：您可以对您的个人信息的处理作出决定，并限制或拒绝我们处理您的个人信息。
 * 撤回同意的权利：您可以撤回同意。请理解，每项服务均需要若干基本的个人信息来完成。在您撤回同意后，我们将不再处理相关的个人信息，并因此而无法向您提供相应的服务。但您撤回同意并不影响之前基于您的授权所进行的个人信息处理。

为安全起见，我们在处理您的请求之前可能会核实您的身份。我们将在核实您的身份后及时响应您的请求，并在核实您的身份后15天内作出答复和合理解释，或告知您解决纠纷的外部途径。

在以下情形中，我们将无法响应您的请求：

 * 与我们履行法律法规规定的义务相关的；
 * 与国家安全、国防安全直接相关的；
 * 与公共安全、公共卫生、重大公共利益直接相关的；
 * 与刑事侦查、起诉、审判和判决执行等直接相关的；
 * 我们有充分证据表明您存在主观恶意或滥用权利的；
 * 出于维护您或其他个人的生命、财产等重大合法权益但又很难得到本人同意的；
 * 响应您的请求将导致您或其他个人、组织的合法权益受到严重损害的；
 * 涉及商业秘密的。

如何联系我们

如果您对本隐私声明和您的个人信息的处理有任何疑问或疑虑，可以将您的问题发送至 dataprotectionofficer@Delinian.com 或发送至以下地址：Delinian
 Limited，香港铜锣湾登龙街18号V-Point 12楼。

保护您的信息

我们将努力确保您的个人信息安全，并采取适当的技术和组织措施保护您的个人信息免遭丢失、未经授权的使用、披露或破坏。尽管我们会尽最大努力保护您的个人信息，但我们无法保证任何信息传输均无风险。

我们要求我们的所有员工、承包商和信息处理者（即代表我们处理个人信息的第三方）对上述信息保密，不将其用于除履行我们要求的服务之外的任何目的。


ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN THE PEOPLE’S REPUBLIC OF CHINA

We also comply with specific requirements stipulated by PIPL (“Personal
Information Protection Law of the People’s Republic of China”) and other
relevant Chinese rules and regulations. This section of the Privacy Notice
supplements the information in this rest of the Notice.


OUR LEGAL BASIS FOR PROCESSING THE PERSONAL INFORMATION

We will process your personal information in accordance with the principles of
legality, legitimacy, necessity, and good faith. We will obtain your consent
before processing your personal information, where required. Especially, when we
want to process your sensitive personal information, we will obtain your
separate consent or your written consent according to laws and administrative
regulations.

If we process your personal information beyond the content in this Privacy
Notice, we will separately explain the purpose, method, and scope of such
processing to you through page tips, interactive processes, website
announcements, etc., and obtain your consent again.

When it comes to directing marketing, we will request your consent. You will
always be free not to respond. You could easily withdraw the consent at any
time.

You’re fully aware that we may process your personal information outside the
need to obtain the authority and consent from you, under any of the following
circumstances:

 * where it is necessary for the conclusion or performance of a contract to
   which you are a party, or for the implementation of human resources
   management in accordance with the labor rules and regulations formulated in
   accordance with the law and the collective contract concluded in accordance
   with the law;
 * where it is necessary for the performance of statutory duties or statutory
   obligations;
 * where it is necessary for the response to a public health emergency or for
   the protection of the life, health and property safety of a natural person;
 * where such acts as news reporting and supervision by public opinions are
   carried out for the public interest, and the processing of personal
   information is within a reasonable scope;
 * where it is necessary to process the personal information disclosed by you or
   other personal information that has been legally disclosed within a
   reasonable scope in accordance with the provisions of this law; and
 * other circumstances prescribed by laws and administrative regulations.


HOW WE SHARE YOUR INFORMATION

We will not share your personal information with a third party unless we obtain
your separate consent or in circumstances where your consent is not required
according to laws and regulations.

We may share your name, job title, company, address, telephone number and email
with event sponsors. Due to the fact that event sponsors will differ from time
to time, we will inform you of the name and contact information of the sponsors,
purpose and method of processing and obtain your separate consent before sharing
your personal information.

Where we need to transfer your personal information due to merger, division,
dissolution or declaration of bankruptcy, etc., we will notify you of the name
and contact information of the recipient, as well as urge the recipient to
continue to process your personal information based on this Privacy Notice.
Otherwise, we will request the recipient to obtain your consent again before
processing.


STORAGE LOCATION AND INTERNATIONAL TRANSFERS

Your personal information will be stored outside of the People’s Republic of
China. Delinian  Limited (https://www.Delinian.com) , is a global organisation
and will receive your personal information (name, job title, company, address,
telephone number and email).

We may also share your personal information with our corporate affiliates, for
them to send you marketing materials.

We will take necessary measures required by laws including obtaining your
separate consent, concluding standard contractual clauses with the overseas
recipient to stipulate the rights and obligations between us, and will ensure
that the foreign receiving party provides adequate protection for your personal
information under applicable laws.

You could contact us or the overseas recipient to exercise personal information
rights through the contact information listed in this Privacy Notice.


YOUR ADDITIONAL PRIVACY RIGHTS

Under the stipulations of PIPL, you have the following rights:

 * Right to be informed: You have the right to know the processing of your
   personal information. In addition, you have the right to ask us to explain
   this Privacy Notice and the rules governing our processing of personal
   information.
 * Right to access and copy: You can request access to your personal information
   or obtain a copy of your personal information.
 * Right to correct and supplement: You can request that we to make corrections
   or supplements where you find that your personal information is inaccurate or
   incomplete.
 * Right to delete: You can request the deletion of your personal information in
   certain circumstances (for example if you withdraw your consent, or the
   purpose of personal information processing has been achieved, it is
   impossible to achieve such purpose, or it is no longer necessary to achieve
   such purpose;)
 * Right to transfer: You can transfer your personal information to a personal
   information processor designated by you when it meets the conditions
   stipulated by the authorities.
 * Right to make decisions, restrict and refuse: You can make decisions on the
   processing of your personal information and restrict or refuse that we
   process your personal information.
 * Right to withdraw your consent: You can withdraw your consent. Please
   understand that each service needs some basic personal information to be
   completed. After you withdraw your consent, we will not process the relevant
   personal information, and cannot provide you with the corresponding services
   as a result. However, withdrawal of consent by you will not affect the
   previous personal information processing based on your authorization.

For security, we may verify your identity before handling your request. After
verifying your identity, we will respond to your request in time, and give a
reply and reasonable explanation within 15 days after verifying your identity,
or inform you of the external ways to solve the dispute.

We will not be able to respond to your request under the following
circumstances:

 * Related to our compliance with the obligations under the laws and
   regulations;
 * Directly related to national security or defense security;
 * Directly related to public security, public health or major public interests;
 * Directly related to criminal investigations, prosecutions, trials and
   enforcement of court decisions, etc.;
 * Where we have sufficient proof that you have subjective malice or abuse of
   rights；
 * For the purpose of safeguarding your life, property and other important legal
   rights and interests or those of other individuals but it is difficult to
   obtain consent;
 * Responding to your request will cause serious harm to your legitimate rights
   and interests, or those of other individuals or organizations.
 * Involving trade secrets.


HOW TO CONTACT US

If you have any questions or concerns regarding this Privacy Notice and the
processing of your personal information, you can send your questions
to dataprotectionofficer@Delinian.com or to the following address: Delinian
 Limited, 12/F, V-Point, 18 Tang Lung Street, Causeway Bay, Hong Kong.


PROTECTING YOUR DATA

We endeavor to keep your personal data secure and take appropriate technical and
organizational measures to protect your personal data from loss, unauthorized
use, disclosure or destruction. Although we do our best to protect your personal
data, we cannot guarantee that any transmission of data is without risk.

All our employees, contractors and data processors (i.e. those third parties
that process personal data on our behalf) are required to keep such data
confidential and not to use it for any purpose other than the performance of
services we have requested.

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